outline construction environmental managment …€¦ · 001 22/01/2011 outline issue only e mason...

Construction Environmental Management Plan

EO788 – Energy from Waste CHP Facility

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OUTLINE CONSTRUCTION

ENVIRONMENTAL MANAGMENT

PLAN

Project Name: Energy from Waste CHP Facility

Project Number:EO788

Document Reference: EO788/CEMP/001

Location: Devonport, Plymouth

Approved by:

Dated:

Signed:

Kier Project Manager

Prepared by:

Dated:

Signed:

Kier Environmental Adviser

Accepted by:

Dated:

Signed:

Supervising Engineer



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Issue and Amendment Record

Revision

Number

Date Description of Change Produced

/ Amended

by

001 22/01/2011 Outline Issue Only E Mason

002 31/03/2011 Planning E Mason

003 21/04/2011 Update with details from ES E Mason



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Contents

Section Title

1 Introduction

1.1 Scope of works

2 Environmental Management

2.1 Impacts and Aspects Matrix

2.1.1 Environmental Risk Assessment

2.2 Nuisance

2.2.1 Dust

2.2.2 Noise

2.2.3 Vibration

2.3 Heritage and Archaeology

2.4 Waste Management System

2.4.1 Environmental Permitting

2.4.2 Segregation of Waste

2.4.3 Disposal of Non-Hazardous Waste

2.4.4 Disposal of Hazardous Waste

2.4.5 Waste Reporting and Records

2.5 Water

2.6 Transportation & Traffic Management

2.7 Ecological Management

2.7.1 Bats

2.7.2 Reptiles

2.7.3 Flora

2.7.4 Unexpected flora and fauna

2.8 Land Contamination

2.9 Resource Use

2.9.1 Material Reuse on site

2.9.2 Energy Consumption

2.9.3 Water usage

2.10 Visual Amenity

2.11 Considerate Constructors

2.11.1 Community Liaison

3 Pollution Prevention

3.1 Pollution Prevention Planning & Emergency Response

4 Project Management

4.1 Licences/Consents/Exemptions

4.2 Site Environmental Documentation

4.3 Reporting

4.4 Auditing and Monitoring

4.5 Training

Appendices

A Site location map

B Impacts and Aspects Matrix

C Preliminary Risk Assessment

D KG Greentop – Guide to Environmental Permits and Exemptions



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1. Introduction

Kier has a sustainable vision for all its construction sites based on three balanced

and interlocking elements strong and diverse environmental understanding,

fundamental improvements in environmental management and use of resources,

and an understanding of its social responsibility. The Kier Environmental

Management Procedure sets out the objective to achieve environmental and

social development simultaneously with a view to continuously improve the

service and commitment it shows.

A description of the site's location and characteristics can be found in Chapter 4

of the Environmental Statement accompanying the planning application. See

Appendix A, Site Location.

This Construction Environmental Management Plan (CEMP) document has been

produced in outline format to accompany the planning application, and highlights

the areas which would be covered by a completed CEMP which would be compiled

prior to any works commencing on the site. This document also refers to

associated documentation which on a live project would include the following

supporting documents:

Pollution Prevention Plan

Traffic Management Plan

Construction Phase Plan

Site Waste Management Plan

BRE SMARTWaste Plan

Appropriate reference has also been made to Plymouth City Council's "Code of

Practice: Control of Pollution & Noise from Demolition & Construction Sites".

1.1 Scope of Works

The works are described in Chapter 6 of the Environmental Statement

accompanying the planning application.

2.0 Environmental Management

The management systems in place conform to BS EN ISO14001 and all sites

comply with these systems. Details of the management system are clearly

defined within the management system process maps, which should be followed

from tender and prequalification stages, through to project close down. The

process maps are available to all personnel. The EMS will be regularly monitored

and audited by appropriate personnel, throughout the duration of the works. It is

the responsibility of the Project Manager to ensure development, approval and

effective implementation of the environmental management system. This should

be undertaken with the support of environmental manager, specialists and other

suitably qualified personnel. It must also be made clear to all site personnel that

each individual has a responsibility to ensure no environmental incidents occur.

The following outlines the processes and plans to be implemented on site to

ensure all environmental aspects and impacts are identified and sufficient

measures are put in place to reduce risks associated with the works.

2.1 Impacts and Aspects Matrix

In line with procedures, an Impacts and Aspects Matrix has been completed which

clearly identifies all applicable legislation in relation to the identified



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environmental aspects for this project, reference number EO788. This document

can be found in Appendix B.

2.1.1 Environmental Risk Assessment

Using the information obtained through the Impacts and Aspects Matrix, an

environmental risk assessment has been undertaken. This assessment will be

used to determine the mitigation methodology to be utilised at EO788. This draft

document can be found in Appendix C. Where significant risks are identified,

specific management plans are to be put into place and details of these will in due

course be found within this CEMP. Each management plan will be thoroughly

assessed by all project management and method statements will incorporate the

mitigation for the assumed risk. Any changes to works packages must be

reassessed prior to any commencement of work.

2.2 Nuisance

Nuisance for the purposes of this document is broken into four sections, namely

Dust, Noise, Vibration and Lighting. The following sections detail activities and

control methods to be implemented on the project.

Sensitive receptors likely to be affected by construction nuisance include the

residential properties closest to the development boundary and residential

properties along construction traffic routes. There is a stream known as Weston

Mill Creek and a small un-named tributary stream located to the north and north

east of the site which are also to be classed as sensitive receptors. These

discharge into an estuary with the tidal range extending upstream beyond the

site.

2.2.1 Dust

Mechanical disturbance of granular material exposed to air creates atmospheric

dust, this type of dust generation is termed as ‘fugitive’ as it is not discharged

into the atmosphere in a confined stream. The potential sources of these fugitive

dust emissions are outlined below:

• Site clearance

• On site earth moving operations, site levelling, cut and fill etc

• Vehicle movements over haul roads

• Vehicle movements on site during dry periods

• Wind blowing across the site during dry periods

• Stockpiling of excavated materials

• Cutting and grinding

• Accidental spillage and loss of load from vehicles carrying loose material

• Deep excavations

The generation of this fugitive dust required consideration of additional factors

such as:

• Prevailing wind (speed, direction)

• Prevailing climate, including rainfall

• Location of sensitive receptors (including residential and commercial

properties, habitats and watercourses)



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Prevailing winds are specifically important when considering fugitive dust. The

speed of winds can determine the dispersion of dust; high winds can increase the

initial generation of dust, in addition to carrying the dust over greater distances.

A dust impact assessment has been undertaken and is presented in Chapter 13 of

the Environmental Statement accompanying the planning application.

Appropriate preventative measures to control dust emissions can significantly

reduce the potential for dust generation. Implementation of the following

methods will help to minimise risk.

Risk Mitigation

Construction

Traffic

• All construction traffic will follow specifically designated

routes

• Speed limits will be put into place on site for all vehicular

movements

• All vehicles carrying loose material will be covered

• Wheel wash facility to be used for vehicles leaving site

Highways • Where appropriate, use of road sweepers will be

incorporated to ensure highways remain clear of dust and

mud

• Road edges and pathways will be swept by hand and

damped down as necessary

Stockpiles • To be sealed or sprayed with chemical bonding agents as

required

• Location of stockpiles away from any sensitive receptors

• To be seeded to allow the growth of grass if stockpiled for

long periods of time

Dust

Suppression

• Mobile bowsers to be deployed on site at regular intervals

Activity to be increased during significantly dry and windy

periods

• Where necessary, use of hoardings to be considered to

ensure reduction in dust migration

• Deliveries of significantly dusty materials to be sprayed to

reduce dust potential

• All cutting and grinding operations to conducted in ways to

reduce risk of dust migration (wet cutting techniques etc)

Monitoring • Ongoing monitoring to be undertaken by site personnel on

regular basis, both on and off site to ensure no migration of

dust

• Regular liaison with EHO and Client to be undertaken

• Regular reviews of mitigation methodology to be undertaken

by Environmental Manager and Project Manager

2.2.2 Noise

Noise has the potential to cause disturbance, given the nearby location of

residential housing. The site is directly adjacent to low-rise flats on Talbot

Gardens and visible from housing on Savage Road, Furze Park and Wilkinson

Road. The level of the roof of the boiler house is about equal to that of some of

the windows in the flats on Talbot Gardens. Therefore, it is essential that the

works comply with any conditions which will be laid out by the Local Authority. It

is expected that a condition will be attached to the planning permission requiring

adherence to Plymouth City Council's "Code of Practice: Control of Pollution &

Noise from Demolition & Construction Sites". In particular this specifies that the

Council’s policy on hours of work is as follows:



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Monday to Friday 8am - 6pm

Saturday 8.30am - 1pm

No Sunday, Bank holiday or Public holiday working

Work may be permitted outside of these hours in exceptional circumstances and

only by prior agreement with the Council and will be conditional on the contractor

informing local residents in advance of the proposed activity.

A noise and vibration impact assessment has been undertaken and is presented

in Chapter 14 of the Environmental Statement accompanying the planning

application.

A noise mitigation plan will be developed which will detail noise limitations to be

set on site, drawing on Appendix 2 of Plymouth City Council's "Code of Practice:

Control of Pollution & Noise from Demolition & Construction Sites".

Set locations will be identified for noise monitoring and a system in place for

recording complaints or concerns from local residents.

In addition our team will embrace best practice with regards noise minimisation.

Best practice will include:

• All construction plant and equipment will comply with EU noise

emission limits.

• Plant will be serviced regularly to minimise adverse noise impacts.

• All vehicles and mechanical plant used for the purpose of the works will

be fitted with effective exhaust silencers and maintained in good

efficient working order.

• Selection of inherently quiet plant where appropriate. All major

compressors will be ‘sound reduced’ models fitted with properly lined

and sealed acoustic covers which will be kept closed whenever the

machines are in use and all ancillary pneumatic percussive tools will be

fitted with mufflers or silencers of the type recommended by the

manufacturers.

• Machines in intermittent use will be shut down in the intervening

periods between work or throttled down to a minimum.

• Plant and equipment such as flat bed lorries, skips and chutes will be

lined with noise attenuating materials. Materials will be handled with

care and be placed, not dropped. Materials will be delivered during

normal working hours.

• Plant reversing near dwellings have banksmen in place of ‘beepers’.

• All ancillary plant such as generators, compressors and pumps will be

positioned so as to cause minimum noise disturbance, i.e. furthest

from receptors or behind close boarded noise barriers. If necessary,

acoustic enclosures and /or shielding will be provided.



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Where practical, noise barriers, close in to construction works, when working in

the vicinity of properties on Talbot Gardens, will be provided. This will provide

additional mitigation for the short-term significant construction noise effects at

these properties.

2.2.3 Vibration

A noise and vibration impact assessment has been undertaken and is presented

in Chapter 14 of the Environmental Statement accompanying the planning

application. It is anticipated that the works should not pose any significant risks

in relation to vibration.

Best practice should be utilised at all times, and ongoing monitoring undertaken.

Where it is deemed that vibration may pose an environmental risk, this should be

fully investigated by the Project Manager and Environmental Manager.

2.2.4 Light Disturbance

Due to the location of properties nearby to the site, especially the low-rise flats

on Talbot Gardens which are set at a higher level, but directly adjacent to the site

and overlook it, consideration will be given to the location and angle of lighting to

ensure minimum potential for disturbance to local residents. Where lighting is not

required during night hours, it will be switched off. The impact of lighting on

amenity has been assessed in the landscape and visual impact assessment, which

is Chapter 8 of the Environmental Statement accompanying the planning

application.

Additionally, lighting arrangements will also take into consideration the potential

disturbance of wildlife and ecology. The impact of lighting on ecology has been

assessed in the ecology assessment, which is Chapter 7 of the Environmental

Statement accompanying the planning application. The lighting design will

minimise the impacts of light spillage on adjacent retained habitats through the

attachment of directional hoods to lights and the use of low pressure sodium

lamps. Non-essential lighting will be fitted with automatic cut-off switches.

2.3 Heritage and Archaeology

A cultural heritage assessment has been undertaken and is presented in Chapter

9 of the Environmental Statement accompanying the planning application.

It is not anticipated that there are any archaeological sensitive areas within the

site boundaries. However, the following table outlines the procedures which will

be followed in the event of such a find or discovery.

The following procedure must be followed in the event of a find:

Immediately stop works in the area of the find

Protect the find and the area surrounding by fencing/blocking off and

immediately contact the site manager

Contact the archaeologist and obtain advice on how to proceed

All significant finds must be reported



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2.4 Waste Management System

In line with the Site Waste Management Plans Regulations 2008 an outline Site

Waste Management Plan has been completed – see Appendix 15.1 of the

Environmental Statement accompanying the planning application. The Site Waste

Management Plan format has been agreed as the BRE SMARTWaste (an online

tool) and can be accessed at all times on site for the duration of the project.

Reviews of Site Waste Procedures and the Site Waste Management Plan will be

undertaken at 3 monthly intervals, or less if required. Site personnel will be

trained in the use of the SMARTWaste Plan.

2.4.1 Environmental Permitting

Please refer to Appendix D for a concise explanation of the Environmental

Permitting Regulations in relation to the works. Any activities within the site

which may fall into the Environmental Permitting Regime need clarification and

appropriate licences or exemptions. The site will maintain regular contact with the

Environment Agency with regards to any issues arising through the

Environmental Permitting Regulations.

2.4.2 Segregation of Waste

To ensure maximum potential for reducing waste to landfill, and encouraging

reuse and recycling, waste will be segregated. Separate skips will be made

available for all types of waste. Each skip will be clearly labelled and site

personnel will be informed of procedures within the induction. Regular monitoring

will be undertaken to ensure correct procedures are followed at all times. The

skips will be emptied at regular intervals to prevent overfilling. Toolbox Talks will

be undertaken with all site personnel to ensure full understanding of waste

procedures.

2.4.3 Disposal of Non-Hazardous Waste

All non-hazardous waste will be removed from site within strict adherence to all

waste legislation requirements, including Duty of Care Regulations. Prior to any

agreed use of hauliers or waste disposal sites, the appropriate licences will be

thoroughly checked to ensure that particular waste streams can be accepted and

carrier licences are valid. This can only be undertaken by authorised personnel

and copies of all necessary licences must be retained on site at all time and

reviewed for expiry. No waste will leave site without appropriate waste transfer

notes. It is essential that all waste transfer notes are inspected for detail and

must contain the correct description of waste as well as the correct waste code, in

line with the List of Waste Codes Regulations. Only authorised and fully trained

personnel may sign waste transfer notes. Regular audits will be undertaken to

ensure correct procedures are being followed.

There should not be any significant quantities of inert waste taken off site as the

intention is to design the project creating an earthworks balance on site, using all

material suitable for re-use on an industrial site (EA guidelines). Surplus material

will be used in site reprofiling.



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2.4.4 Disposal of Hazardous Waste

Although limited hazardous waste arisings are expected, the site must be

registered as a producer of Hazardous Waste. No hazardous waste must leave

site without the correctly completed Consignment Note. The consignment notes

must contain all necessary information including waste description and hazardous

waste registration number. Any carriers removing hazardous waste must have

appropriate licences and disposal sites must be verified to be able to accept waste

being sent. These checks and signing of consignment notes can only be

undertaken by authorised personnel. All hazardous waste must be stored on site

in appropriate, covered or locked skips. No mixing of hazardous and non-

hazardous waste is authorised.

2.4.5 Waste Reporting and Records

All waste transfer notes will be held on site throughout the duration of the

project. Each waste transfer will be fully documented and the Site Waste

Management Plan updated accordingly. Each month, a comprehensive waste

report will be compiled by the project team, detailing the exact movements of the

previous months waste, including destination and treatment. These reports will be

forwarded to head office for analysis. Regular auditing will be undertaken of all

waste management systems.

2.5 Water

A stream known as Weston Mill Creek and a small un-named tributary stream

located along the north and north east boundaries of the site discharge into an

estuary with the tidal range extending upstream beyond the site and therefore it

is essential that no hydrocarbons, solids or any other contaminants enter this

water course.

There are various proposed works which need to be carried out within and

adjacent to the watercourses e.g. the demolition of two existing culvert road

bridges and construction of their replacement clear span bridge. The design of the

new structure has been significantly influenced by the need to ensure protection

of the water environment, specifically the span of the new bridge will keep the

new abutments clear of the water.

Land Drainage Consent will be required from the Environment Agency under the

Land Drainage Act of 1991 well in advance of construction commencing.

Additional planned protection measures include extension of the existing sheet

pile abutments and construction of the new abutments behind these so that any

loose material cannot enter the watercourse. The excavation will be dewatered an

all pumped water will be discharged through a series of ‘Siltbuster’ settlement

tanks before it is allowed to enter the stream. In addition to this, during the more

environmentally risky operations such as piling or concrete placement the stream

will be continually visually monitored for turbidity and any impending risk of

contamination. Plant maintenance checks will also be increased in frequency

during these operations.

Short term surveillance monitoring will be undertaken in advance of construction

in order to establish a baseline. The short term surveillance monitoring should

include specific water quality monitoring for shallow groundwater and surface



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water and assessment of existing Water Framework Directive data regarding the

ecological status of the watercourse.

Further surveillance monitoring will then be undertaken during construction.

Regular weekly monitoring and water sampling will be undertaken at specific

points, these inspections should include visual reference, turbidity and pH levels.

All records of water monitoring inspections will be kept on site throughout the

duration of the project and be readily available for inspection by the Client, Kier

or any regulatory body. In periods of heavy rainfall or excessive vehicle

movements within the vicinity, monitoring should be increased to reduce risks of

pollution incidents.

Spill kits will be made available, and site operatives trained in their use, to deal

with any spillages. All spill kits will be fully stocked at all times and an inventory

of equipment within the container will be clearly displayed within the lid.

Due care and attention must be made with regards to potential surface run-off

affecting the water course, and stockpiling of any materials should ideally not be

located within the vicinity of the watercourses. Where stockpiles have to be

located in the vicinity of a watercourse a 7 m buffer strip should be in place to

reduce pollution risks.

The positioning of fuel storage tanks and other potentially polluting materials and

maintenance/refuelling facilities should be on bunded areas of hard standing with

dedicated drainage systems. Stored materials on site will be checked regularly for

containment integrity (both primary and secondary), quantity stored and security

of storage.

A temporary swale will be installed along the eastern side of the site, into which

runoff can be directed to reduce silt and suspended solids before discharge into

the watercourse.

Construction of concrete structures during the construction phase would be

monitored to prevent associated contaminated material entering any

watercourses. Pre-cast work or permanent formwork will reduce the amount of

in-situ concreting required adjacent and above the watercourses. Washing out of

concrete wagons or other equipment used in concreting operations will be

undertaken in designated contained washout areas. These will be located away

from all watercourses and drains and will be impermeable to prevent infiltration

to ground.

Piling activities required for the waste bunker and building foundations may

extend down to the Secondary (B) Aquifer (Saltash Formation). A Foundation

Works Risk Assessment will be prepared by the Contractor to confirm that the risk

of contamination of the Secondary Aquifer through the mobilisation of

contaminants within the made ground is low with the proposed use of rotary

bored piles. The risk assessment will be agreed with the Environment Agency.

Where overpumping is required, the water should be put through an appropriate

sized settlement tank, the flow rate set up must allow appropriate timescales for

settlement. If the discharge is still showing as heavily silted, then a ‘Siltbuster’

settlement tank (or series of) is to be used with flocculants if appropriate.

Permission for any dewatering activities will need to be sought from the

Environment Agency under the terms of the Water Act 2003, well in advance of

construction commencing.



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‘Betterment’ of the aquatic ecological environment will be achieved by removal of

a disused culvert with footway over, which lies in Weston Mill Creek and may

have caused flow restrictions in the past. The creek bed will be returned to its

‘natural’ state and an extensive clean-up of the rest of the creek between

Wolseley Road and the site will be completed (removing the years’ accumulation

of rubbish).

2.6 Transportation and Traffic Management

A traffic management plan will be implemented on the site, details will in due

course be found in the Construction Phase Health and Safety Plan. The plan will

outline timings of deliveries and routes to be taken by hauliers to ensure minimal

disruption to local residents and businesses. This will include potential risk for

noise disturbance as well as minimising additional traffic during peak periods.

In the initial phase the site will be within the secure boundary of HMNB Devonport

and as such, the traffic management plan is likely to affect operations with the

dockyard. Close liaison between KCL, the MoD and Babcock marine (dockyard

operator) is essential. Early works will involve re-alignment of the boundary fence

so as to re-designate the site as outside the boundary of HMNB, although still on

leased land owned by HMNB. Close liaison will continue due to this fact and the

proximity to HMNB boundary.

Other enabling works affecting traffic management include construction of a new

access road along the edge of Camel’s Head car park adjacent to Weston Mill

Creek and another for Bull Point access for HMNB (as the existing access will be

permanently cut-off).

2.7 Ecological Management

An ecological assessment has been undertaken and is presented in Chapter 7 of

the Environmental Statement accompanying the planning application.

Good practice should be undertaken during the construction phase in order to

avoid or reduce ecological impacts, including:

• Dust minimisation methods (e.g. wetting of dust-producing plant and

machinery, covering of all vehicles carrying spoil) to avoid impacts on

retained vegetation, in particular Blackies Wood Biodiversity Network

Feature (BNF).

• Night working should be avoided wherever possible and all construction

lighting should be directed away from retained areas of habitat.

Security lighting and non-essential lighting should be fitted with

automatic cut-off switches.

• Where works within and in close proximity to watercourses are to be

conducted, namely the removal of the culverts and construction of the

bridge, pollution prevention controls should be utilised to reduce the

risk of sediment pollution resettling further downstream and potentially

smothering benthic habitats. Refer to Appendix 6.4 of the

Environmental Statement accompanying the planning application for

details.



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• All clearance works, tree felling and scrub removal should be

undertaken outside the bird nesting season (i.e. should be undertaken

during the period September – February), although if works cannot be

avoided during the nesting season (March – August) then an ecologist

should supervise any works.

2.7.1 Bats

The need for a bat activity survey was discussed in a meeting with the

Environment Agency and Natural England in November 2010. During this meeting

it was agreed that the bare ground, hard standing and aggregate spoil which will

be lost as a consequence of the development are unimportant as bat habitat, and

since no linear features that bats might use are to be removed as part of the

development, a bat activity survey to identify the presence/absence of

foraging/feeding and/or commuting bats would not be required.

A tree survey for the potential to support roosting bats was undertaken on two

semi-mature oak trees in the southwest of the site that are to be felled as a

result of the development. Both trees have negligible potential to support

roosting bats.

The linear features of the continuous scrub within Blackies Wood may provide

foraging/feeding and/or commuting habitat for bats roosting off the site, since

they are well structured and provide potential flight paths or corridors. The

mature trees may provide suitable roosting habitat for bats, particularly since

some of these trees provide suitable features, such as cracks, crevices, flaking

bark and rot-holes.

The site is considered to be of negligible conservation value for roosting bats and

low (parish/neighbourhood) value for foraging/feeding and/or commuting habitat

for bats.

The lighting design will minimise the impacts of light spillage on adjacent retained

habitats through the attachment of directional hoods to lights and the use of low

pressure sodium lamps. Non-essential lighting will be fitted with automatic cut-off

switches.

2.7.2 Reptiles

A Reptile Survey has been undertaken and can be seen at Appendix 7.5 of the

Environmental Statement.

The presence of reptiles within the site will require appropriate mitigation, in the

form of translocation, to protect the species in relation to the proposed

development. Reptile translocation will be undertaken following best practice

guidance prior to the commencement of construction; see Method Statement in

Appendix 7.5 for details.

In the unlikely event of the discovery of any reptile during the construction

works, immediate surrounding works will cease. The site foreman will contact the

project manager, who will in turn contact the site ecologist. No works may

commence within the area until the site ecologist has given permission. Species

identification training and posters will be available on site to assist all site

personnel with identification.



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2.7.3 Flora

Site preparation works include the removal of the clutter of activity, levelling of

earth mounds and clearance of areas of scrub and trees using specialist

contractors. Two trees require removal – refer to Appendix 8.2 of the

Environmental Statement accompanying the planning application, for details.

Individual trees and tree groups not requiring removal will be protected in

accordance with BS5837:2005 – Trees in Relation to Construction. A Tree

Protection Zone will be established within which no work could take place without

the prior authorisation of a suitably qualified arboricultural consultant. The

alignment of proposed protective fencing is shown in Appendix 8.2. Clear signage

will be placed on all fencing surrounding the protected tree area. The fencing will

be regularly checked and any areas found to be of poor quality or damaged, will

be repaired or replaced immediately. All site personnel will be made aware of

which areas are not to be entered within the Induction Programme and this will

be reinforced throughout the duration of the works through regular toolbox talks.

The existing Blackies Wood habitat will be managed to promote the wildlife which

already exists. Landscape design will incorporate native planted woodland and

shrubs that will represent the existing landscape character; the creation of wildlife

corridors boundaries; the reinstatement of an existing ditch to connect to a newly

created freshwater pond; areas of open species-rich neutral grassland and bird,

bat and insect boxes. Further detail can be found in the Design and Access

Statement accompanying the planning application.

The Japanese knotweed within Blackies Wood BNF and on the slopes of Table Top

Mountain (outwith the site boundary but adjacent to the construction compound)

will be treated and eradicated to halt the spread of this invasive species.

2.7.4 Unexpected discovery of flora or fauna

Where any unexpected species is located by any personnel on site, all works

within that area must cease immediately. Site management must be immediately

informed along with the site ecologist. No further work may take place within that

area until confirmation has been given by the site ecologist and site

management.

2.8 Land contamination

A land contamination assessment has been undertaken and is presented in

Chapter 10 of the Environmental Statement accompanying the planning

application.

Previous ground investigations at the site have not encountered significant

concentrations of contaminated soils and in addition, it is expected that the

majority of excavated material should be suitable for re-use across the site. The

proposed development will comprise a large proportion of hardstanding, i.e.

tarmac and concrete cover. There will, therefore, be a reduced pathway between

any contamination and site receptors.

During the site induction all personnel will be made aware of their responsibility

to be vigilant regards potential soil contamination. Key personnel are ground-

workers, machine operators and their banksmen. They will report any suspicions



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of contaminated soil to site management who will then instigate the following

actions.

If contamination is encountered during site works, it should be reported to the

Local Authority and may require remediation.

Remediation options for contaminated soil typically include removal to a suitable

landfill site, remediation on-site or the placement of a ‘clean cover system’ in

areas of soft landscaping. Imported soils for the clean cover system, or other fill

materials required for the new development, must be free of contamination. All

imported topsoil must comply with the Environment Agency’s Soil Guideline

Values (SGVs), generated using CLEA software, for residential gardens and with

BS 3882: 2007, Specification for Topsoil. In addition, the source and supplier of

any imported materials must be provided to the Local Authority together with

appropriate analysis certification. Further guidance can be found in report BRE

465.

Any excavated soils removed from site for disposal to a landfill should undergo

Waste Acceptance Criteria (WAC) testing in order to correctly classify the material

in terms of waste disposal. The results of the WAC testing should be supplied to

the chosen waste acceptor at an early stage of the development in order to locate

a suitable landfill site.

The risk from contaminated dusts is considered to be low, due to the lack of

contamination identified within site soils, and can be controlled with good working

practices such as dust control measures during construction works.

2.9 Resource use

Kier will ensure where practicable, the use of recycled or sustainable materials

will be utilised. In line with company protocol, all wood should be obtained from a

certified sustainable source, such as FSC.

A dedicated area will be maintained for storage of all materials and due care and

appropriate handling will be undertaken at all times to reduce any risk of

damages and wastage. Packaging of items should not be removed until required,

to ensure maximum potential for returning of unused goods.

As much office waste as possible will be sent for recycling and strategies put in

place to ensure minimal wastage, for example avoiding unnecessary printing etc.

Where possible, use of local suppliers will be considered to reduce transportation

costs and maintain a low carbon footprint.

Waste disposal options will be investigated to ensure minimal transportation

requirements where possible.

Onsite crushing and reuse of materials will be incorporated into the project. This

will aid reduction in waste going to landfill as well as minimising vehicular

movements on the local road systems.



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2.9.1 Energy Consumption/Monitoring

Switch it off schemes and other energy saving campaigns will be implemented on

site to encourage all personnel to consider their carbon footprint both at work and

home. Use of car sharing and buses will be encouraged. Posters will be clearly

displayed within the site offices to ensure all personnel are aware. This will also

be covered within the site induction and regular toolbox talks held relating to the

subject.

2.9.2 Water usage

Within site accommodation, water boilers rather than kettles will be used to

encourage water savings. Taps will be switched off when not in use and all staff

will be made aware of water saving techniques. Every effort to ensure reduction

in water use should be implemented where available. Where possible,

consideration will be given to rainwater harvesting on site.

2.10 Visual Amenity

Kier will ensure that the site boundaries are kept clean and tidy at all times. Any

hoardings and/or fencing will be well maintained and kept free of graffiti and non-

site specific posters. Damaged or unsightly fencing must be repaired or replaced

as soon as possible. Local roads will be kept free of excessive dirt and mud, road

sweepers and wheel wash facilities are to be used to prevent build up. It is the

responsibility of the site management to ensure the cleanliness of the site is

maintained and allocated personnel will be identified to carry out regular checks.

2.11 Considerate Constructors

As part of Kier’s Environmental Management System, it is expected that all sites

will register the site with the Considerate Constructors Code of Practice. The site

will target to maintain a score of no less than 33 on each site monitor's visit. The

site will clearly display the associated posters and banners allowing local residents

to see clearly all contact numbers.

Kier will ensure all works carried out are undertaken in a manner which not only

ensures best practice, but ensures minimal disruption and cause for complaint by

the public.

2.11.1 Community Liaison

Kier will actively seek to ensure community liaison is maintained throughout the

duration of the works. Site specific activities will be planned which ensure

interactivity with local communities, schools, colleges and charities. Events such

as family fun days are to form part of the culture of the project and will

encourage local residents to participate as well as offer opportunities to meet and

discuss the project with site management.

3 Pollution Prevention

A Pollution Prevention Plan will in due course be produced detailing all procedures

to be followed on site by all site personnel and sub-contractors. This document

will be clearly displayed within the project offices and all site personnel made fully

aware of all procedures and methodology detailed within it.



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3.1 Pollution Prevention Planning and Emergency Response

In the event of an Environmental Incident, procedures must be followed to ensure

risks of further spillages/migration of pollutants are minimised. A subcontractor

will be employed to be on standby in the event of a major incident. The

Emergency Response will be found within the Pollution Prevention Plan. Contact

details will be clearly displayed on site and information clearly explained to all site

personnel. The Pollution Prevention Plan will contain a clear detailed plan of the

site which indicates the location of sensitive receptors such as watercourse,

drainage and bore holes. An appropriate number of spill kits will be located within

these areas and clearly marked on the plan. It is the responsibility of the site

management to ensure all spill kits are fully stocked at all times, and an

inventory of equipment within the container to be clearly displayed within the lid.

4 Project Management

The following section will outline documentation and consents required for the

project. Kier will follow all systems as outlined by the Client and internal

requirements.

4.1 Licences/Consents/Exemptions

Site management will regularly liaise with the Environment Agency and other

regulatory bodies with regards to all consents, exemptions and licences. Any

applications will be made with consideration of appropriate timescales. A consents

schedule will be completed and held on site files detailing information from date

of application. Where specific limitations are set through any licence, consent or

exemption, this is to be clearly identified and regularly reviewed to ensure

compliance.

Land Drainage Consent will be required from the Environment Agency under the

Land Drainage Act of 1991.

Permission for any dewatering activities will need to be sought from the

Environment Agency under the terms of the Water Act 2003.

4.2 Site Environmental Documentation

All environmental documentation must be kept on site at all times and be

available for inspection by internal and external auditors, as well as the client and

management. The folder structures will conform to the Kier Document Control

systems. Where any document is amended, previous versions will be superseded

and documents transmitted in line with procedures. Site personnel will be made

aware immediately, if any significant changes in works procedures are

implemented.

Initial start up documentation will include the following:

Site Set Up Checklist

Impacts and Aspects Matrix

Environmental Risk Assessment


Site Waste Management Plan

Pollution Prevention Plan

Training and Responsibilities Matrix



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Project Consents Schedule

Ongoing weekly environmental inspections will take place on site by authorised

personnel. The findings of these inspections and any associated actions will be

appropriately documented in agreed format. Copies will be held on site at all

times.

4.3 Reporting

Monthly reporting of waste figures and environmental incidents will be

undertaken by the site. This information will form part of KCL’s monthly board

reporting system.

4.4 Auditing and Monitoring

A regular audit schedule will be set up at project start. This audit schedule will

include both internal and external audits for the project. It is the responsibility of

the site management to ensure all documentation and evidence required for audit

purposes is kept up to date and freely available for inspection at all times. The

site environmental management system will be audited to the standards set out

by ISO14001. Additional legal compliance audits will also be undertaken. Any

system failures will be documented and appropriate corrective actions issued and

implemented.

Weekly site inspection will be carried out to ensure environmental risks are being

managed appropriately. These inspections will be carried out by suitably qualified

personnel and the appropriate SHE Inspection forms will be completed and signed

off by site management. All documents will be filed and retained on site for

auditing purposes. Any failure to undertake such monitoring will be deemed as a

non conformance with procedure and appropriate corrective action will be

implemented.

4.5 Training

All Kier site personnel with environmental responsibilities will be suitably trained

and qualified. Where it is indicated that additional specific training requirements

are needed, it is the responsibility of the site management to ensure these needs

are met at the earliest possible opportunity.

The site induction must include a general overview of environmental issues

relating to the site, as well as an overview of how these issues will be managed.

It is expected that all appropriate site personnel will undertake some basic

environmental awareness training.

Environmental Toolbox Talks covering topics relating to site activities must be

given to all site personnel and subcontractors at a period of no less than

fortnightly.

Environmental Bulletins and Newsflashes must be clearly displayed in all

mess/office areas. Any actions relating to these must be implemented

immediately, and all site personnel made fully aware of any changes.



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APPENDICES



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Appendix A

Location of Works


EO788 – Plymouth Energy from Waste

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The image here illustrates the physical proximity and elevations of the

watercourse and the construction site. The flats on Talbot Gardens are shown in

the background.

Talbot Gardens flats


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Appendix B

Aspects & Impacts


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Aspect Legislation * Impact Risk Mitigation Measures

Nuisance – Dust

(ADS 01)

Environmental Protection Act 1990

Clean Air Act 1993

Deposition of dust

Reduction in air quality

Statutory nuisance

Complaints

Legal action

Local Authority Action

Clean-up costs

Risk to Reputation

Monitoring


Damping down methods appropriate to site

Heritage/Archaeology

(ADS 02)

Ancient Monument & Archaeological Areas Act 1979

National Heritage Act 1983

Planning (Listed Buildings & Conservation Areas) Act 1990

Planning & Compensation Act 1991

Loss of heritage/artefacts

Complaints

Legal action

Delay and disruption

Awareness training

Archaeological Assessments

Nuisance - Noise

(ADS 03)


Clean Neighbourhoods & Environment Act 2005

Control of Pollution Act 1974

Anti-social Behaviour Act 2003

Disturbance to residents.

Statutory Nuisance

Complaints

Legal action.

Delay to works.

Risk to Reputation

Planning condition requiring adherence to Plymouth City Council's

"Code of Practice: Control of Pollution & Noise from

Demolition & Construction Sites"

Communication / Considerate Constructors Scheme

Best Practicable Means on site

Waste

(ADS 04)


Control of Pollution Act 1974

Environment Act 1995

List of Waste Regulations

Hazardous Waste Regulations

Clean Neighbourhoods & Environment Act 2005

Duty of Care Regulations

Site Waste Management Plans Regulations 2008

Environmental Permitting 2010

The Environmental Civil Sanctions Order 2010

Disposal costs,

Transportation,

Resource use and landfill

capacity

Breach in Duty of Care

Prosecution

Excess costs of disposal.

Civil Sanction

Site Waste Management Plan – Use BRE SMARTWaste Plans

Checks of Carrier licence and disposal facility consents / licences

Minimise waste arising - Reuse and Recycle

Segregation of wastes

Training, Toolbox Talks

Water

(ADS 05)

Water Industry Act 1991

Water Resources Act 1991

Water Act 2003

Groundwater Regulations 1995

Environmental Permitting 2010

Water quality /groundwater

quality reduction.

Pollution

Water Charges, Resource

consumption.

Groundwater drawdown

Legal Action

Clean-up costs

Failure to meet consent.

Uneconomical us of water

Need for Abstraction Licence

Enforcement action

Surface water and trade effluent consents.

Site operational control procedures

Monitoring compliance

Environmental Incident Procedure, Spill kits/training

Transportation

(ADS 06)

Road Traffic (Vehicle Emissions) Regulations Traffic disruption

Dust and emissions to air.

Complaints

Damage

Disruption

Considerate Constructors Scheme

Include delivery/export conditions/limitations in sub-contract

requirements.

Traffic Management Plan

Contaminated Land

(ADS 07)

Contaminated Land Regulations 2006

Control of Pollution (Oil Storage) Regulations

Contamination of Land

Pollution of Waters

Potential Spillage

Prosecution

Clean-up Costs


Compliance with Oil Storage Regulations

Spill kits & Training

Appropriate storage and handling, investigate disposal options

Ecology - Flora & Fauna

(Disturbance & Harm)

(ADS 08)

Wildlife & Countryside Act 1981

Environment Act 1995

Conservation (Natural Habitats Etc.) Regulations

Wild Mammals (Protection) Act 1996

Protection of Badgers Act 1992

Countryside & Rights of Way Act 2000

The Environmental Civil Sanctions Order 2010

Loss of habitat

Loss of valuable species

Spreading noxious/invasive

species

Legal action

Loss of Reputation

Reinstatement costs

Civil Sanction


Reptile translocation

Japanese knotweed treatment / eradication

Species identification training

Protective fencing and signage of sensitive areas

Onsite ecologists during specific works

Resources

(ADS 09)

Environmental Protection (Controls on Substances that

Deplete the Ozone Layer) Regulations 1996.

Control of Substances Hazardous to Health 1999.


Chemicals (Hazardous Information and packaging for Supply)

Regulations 1994.

Aggregates Tax (Finance Act).

Resource Use/Depletion

Global Warming

Cost

Un-sustainability

Risk to Reputation

Supply chain management and material control

Use of material from sustainable sources.

Use of FSC Timber

Visual Amenity

(Detriment to)

(ADS 10)

Town & Country Planning Act 1990

Planning (Listed Buildings & Conservation Areas) Act 1990

Loss of visual amenity Complaints

Legal action

Delay and disruption

Planning process

Public consultation

Considerate Constructors Scheme



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Appendix C

Preliminary Risk Assessment



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Risk Residual Risk

Environmental Aspect (delete as necessary)

Potential Environmental Impact

O +D x C Total

Control Measures

(add/delete as necessary)

O +D x C Total

Method Statement /Procedure Number

Associated Toolbox Talk

DUST Soiling of flora Contamination of water courses Legal Action by Statutory Authorities

4 2 8 48 Pollution Prevention Plan Dust sheets/damping down via Bowser ENV08 Environmental Monitoring

3 2 6 36 To be covered in the Pollution Prevention Plan -

03 & 21

NOISE Complaints by residents Legal Action by Statutory Authorities Disruption to wildlife

3 2 6 30 PCC Code of Practice ENV08 Environmental Monitoring

Low noise plant/ensure no idling engines

2 2 6 24 PCC Code of Practice 04 & 21

WASTE Pollution/contaminated land Legal Action by Statutory Authorities

4 3 6 42 Site Waste Management Plan ENV08 Environmental Monitoring Duty of Care/Transfer Notes Training Segregation of waste

2 2 8 32 Site Waste Management Plan

08,09 & 24

WATER Contamination of groundwater/surface waters/rivers Impacts on wildlife Potential harm to humans Failure to meet consents Legal Action by Statutory Authorities

4 4 10 80 ENV08 Environmental Monitoring Obtain appropriate licences/consents Spill kits complete and readily available Allow for flooding when positioning

3 3 8 48 Monitoring will be undertaken on a weekly basis, procedures are set out in the Pollution Prevention Plan. An up to date log will be kept in the Environmental file and any findings will be communicated to the relevant persons.

01 02 05 06 16 17 18



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plant, fuel store etc

TRANSPORTATION

Traffic congestion Complaints from public

4 3 6 48 Traffic Management Plan

3 2 4 20 Traffic Management Plan 04 & 21

CONTAMINATED LAND

Impacts on wildlife Legal Action by Statutory Authorities Remediation costs

4 4 8 64 ENV08 Environmental Monitoring Site Waste Management Plan Training, maintain good standards of site housekeeping Work to Control

Pollution (Oil storage) Regulations 2001

3 2 6 30 Contaminated land assessment 1 13 23

ECOLOGY Loss, destruction, harm or disturbance of wildlife or habitat Reduction in endangered species Spreading of invasive plants Legal Action by Statutory Authorities

4 3 10 70 ENV08 Environmental Monitoring Training/Toolbox Talks/Species Identification Information Ecological Assessment Application for appropriate consents/licences Fencing off sensitive areas

2 2 10 40 Ecological assessment 7 10 11 12 19 20 22

RESOURCE USE

Generation of additional waste streams Reduction of fossil fuels Destruction of non-sustainable forests

4 2 6 36 Re-use of materials Prevention of over-ordering Appropriate storage of materials FSC Timber Usage

2 1 4 12 All waste streams have been identified, any additional waste streams will be added to the Site Waste Management Plan Further procedures can be found in the Pollution Prevention Plan

14



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Switch It Off Schemes

VISUAL AMENITY

Impact on visual amenity Complaints by public

3 3 6 36 Careful use of lighting Hoardings if required Good site housekeeping

2 1 4 12 The site will be registered under the Considerate Constructors Scheme in which procedures will be followed.

21

Likelihood of

Occurrence (O)

+ Likelihood of

Detection (D)

X Severity of

Consequence (C) Originator: Dated:

Criteria Rank Criteria Rank Criteria Rank

V High 5 V High 1 V High 10

High 4 High 2 High 8

Moderate 3 Moderate 3 Moderate 6

Low 2 Low 4 Low 4

V Low 1 V Low 5 V Low 2



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Appendix D

Environmental Permitting Regulations Kier Group Greentop



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